Athens Activist Misses The Mark on Injection Wells

Last week, the ran an opinion piece penned by local activist Madelline ffitch regarding Class II injection wells. The column was heavy in rhetoric and anecdotal information, but light on facts.

Though we’ve covered the ins-and-outs of injection wells here on numerous occasions, there remains quite a bit of misinformation continuing to be circulated in our public conversation. Many of these misstatements are repeated in this column, so it seems worth revisiting.

Let’s take a look at some of the more egregious statements, and then separate the facts from the inflammatory.

ffitch: “Outrage about the out-of-state radioactive waste that is being dumped into substandard waste wells in our community…”

Two things off the mark here:

“Substandard waste wells”

As we’ve covered before, Ohio has the most stringent UIC rules in the country. In fact Ohio’s updates to its regulation of injection wells prompted Tom Tomastik, a national expert on injection wells, to state in an email that Ohio “now has the most stringent Class II saltwater injection well regulations in the United States,”.

Ohio’s regulation of injection wells exceeds the standards set for by the EPA, which granted the state primacy in UIC oversight in 1983. In that time, nearly twenty years now, Ohio has “not had any subsurface [water] contamination,” according to Tomastik.

“Radioactive waste”

Those who oppose the development of fossil fuels frequently throw around the phrase “radioactive waste” loosely, and it’s a very misleading term. The radioactive material referenced, in veiled phrasing, is naturally occurring radioactive material – or NORM – and it is surprisingly pervasive in every day life. It even occurs in our bodies in the form of radioactive potassium. It is present in things we use frequently, including public drinking water, Brazil nuts, peanut butter or granite countertops. On average, Americans receive a radiation dose of about 620 millirem each year. None of these levels are dangerous to human health, and the same can be said of NORM returning via flowback from a oil or natural gas well.

This fact has been confirmed by numerous and recent studies on the subject, including a radiological survey report by the Co-Physics Corporation in New York that concluded that “rock cuttings from the gas drilling operations, as sampled during this project, have radionuclide levels that do not pose any environmental health problems.”

This reinforces finding from last year by the New York State Department of Environmental Conservation Supplemental Generic Environmental Impact Statement On The Oil, Gas and Solution Mining Regulatory Program that states, that based upon currently available information, it is anticipated that flowback water do not contain levels of NORM of significance.

In the video below, ODNR Oil and Gas Division Chief Rick Simmers addresses NORM as it relates to oil and gas development.

Radioactive materials that can be associated with oil and gas or injection operations are sometimes referred to as NORM or Naturally Occurring Radioactive Material or TENORM Technically Enhanced Naturally Occurring Radioactive Material. These type of radioactive isotopes are literally in everything, including us.

The Ohio Department of Health is the agency that regulates NORM, TENORM and radioactive issues as a whole. The Ohio Department of Health has tested locations throughout the Utica Shale. They have looked at drill cuttings. They have looked at fluids and have found there are very low levels of NORM well within the established limits by the federal government and reflected in state law. Rick Simmers (January 11th, Covelli Centre, Youngstown)

ffitch: “This week, I talked to a local firefighter who said, as an emergency responder, she does not receive training or equipment to deal with exposure to radioactive hazardous waste,”

For over 12 years, the has conducted numerous workshops – free of charge – to emergency responders. This curriculum has been endorsed by the Ohio Fire Chief’s Association, and serves as a model for other developing states developing similar programs of their own.

To date, nearly a thousand emergency responders hailing from over 40 counties have attended the program, which is conducted several times throughout the year.

ffitch: “Then, just yesterday, I heard the news that a friend is selling his farm and moving because he believes that the injection well near his land threatens the health of the livestock he depends on to make his living.”

It’s unfortunate if the gentleman the author refers to here is moving based on the idea that, somehow, his farm or his livestock would be impacted by a nearby injection well.

Injection wells have been developed in agricultural regions since the days of Constantine. According to the EPA’s History of the UIC Program, the use of injection wells was documented as early as A.D. 300, with large-scale commercial use of injection wells in the U.S. beginning in the1930s.

To date, over 144,000 Class II injection wells have been developed across the United States, with 181 (or .12% of the nation’s total) developed here in Ohio.

The EPA has declared the use of injection wells as a “safe and inexpensive” means of disposal, with the main objective of the UIC program ensuring the protection of underground sources of drinking water. This is why the use of injection wells is regulated under the Underground Injection Control program of the federal Safe Drinking Water Act, passed by Congress in 1974. EPA administers the UIC program, and delegates regulatory authority over SDWA to the state of Ohio. The underground injection program is regulated under Section 1422 of the Safe Drinking Water Act.

With over seventeen centuries of success as a safe means of wastewater disposal, one can rest assured there is no cause to move due to an injection well.

ffitch: “No matter where you stand on other issues – Republican, Democrat, Libertarian, right, left or in between – we can all get together on this one. “

ffitch: “Appalachian Ohio is simply being treated as a big dumpsite for frack-waste trucked in from states that consider this material too hazardous to be dumped in their own backyards. “

In a cross post published this weekend, we covered how this notion is far from fact. Let’s take a quick look some of the highlights coming out of New York and Pennsylvania:

Pennsylvania:

Pa. DEP Secretary Michael Krancer: “Where wastewater cannot be treated and reused/recycled, the best solution for disposing of high TDS wastewater is deep well injection. Using deep well injection should result in no discharge to either surface or ground water, another fact I pointed out in the NRDC letter. Although much of the best geology in the Commonwealth for deep well injection is currently being used for gas storage, exploration for new injection sites does continue, and DEP and EPA will continue to process any permit applications in accordance with applicable laws and regulations.” (July 31, 2012)

Krancer added: “While DEP staff and I are ready and willing to work to improve the UIC program in Pennsylvania, given the current structure of the program, I cannot agree that enacting a moratorium on new permits is a sound position.”

Former Pa. DEP Secretary John Hanger: “The good news about PA drilling wastewater practices is that nearly all shale gas wastewater is either recycled or deep well injected.” (Sept. 18, 2012)

NPR, StateImpact Pennsylvania: “Several new deep injection wells are in the planning process, one in Brady Township, Clearfield County and two in Warren County.” (Aug. 7, 2012)

Pa. Dept. of Conservation and Natural Resources: “If the disposal method is to be an injection well, two permits are needed: one from the PADEP and another from the U.S. Environmental Protection Agency. Appendix 5 of the Oil and Gas Operators Manual and Section 78.18 of the Pennsylvania Code…provide more information on these permitting issues.” (DCNR website)

NY Department of Environmental Conservation: “Wells for Disposal of Brine Produced with Oil and/or Gas” (DEC’swebsite lists the disposal wells located in and regulated by the state of New York).

If these states believe that injection wells are “unsafe”, then how are new ones being proposed there? More importantly, why are the regulators saying that the wells are safe?

The fact is injection wells remain the safest, most effective means of waste disposal, as they have for centuries. These are not new or unique operations taking place in Ohio (or elsewhere, for that matter), but rather a time-tested and proven practice.

In the discussion of Ohio’s continuing development of our homegrown energy resources, it is vital we have an honest, fact-based conversation rather than one based in fear and void of any factual information. Our gift in the Utica Shale is an opportunity too great to be hindered by a conversation that is anything but truth.